Lewis Rice attorneys handled the annual preparation of multiple Affirmative Action Plans (AAP) for a national banking organization with retail banking operations at more than 100 locations throughout the United States. We prepared a strategy whereby all retail employees were "rolled up" into one of a small number of corporate AAPs, greatly increasing the utility of the Plans and the efficiency of the data gathering process. In addition, we counseled federal contractors on the numerous and expanding non-AAP obligations they face every day.

In the first of two consecutive annual audits by the Office of Federal Contract Compliance Programs (OFCCP), our approach was approved and the audit was closed. The next year, OFCCP conducted a compensation audit on another location, and we successfully guided the client through the audit, which again concluded with a finding of no violations.